Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

REVIEW OF SPECIAL EXPOSURE COHORT EVALUATION 

REPORT FOR SEC-00217 

Contract No. 211-2014-58081

Revision 0 

Prepared by 

William C. Thurber 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

July 2015 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
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S. COHEN & ASSOCIATES: 

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program

REVIEW OF SPECIAL EXPOSURE COHORT 

EVALUATION REPORT FOR SEC-00217 

Document No. 

Review of SEC-00217 ER 

Effective Date:

Draft – July 30, 2015

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0 (Draft)

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Task Manager: 

__________________________ 

William C. Thurber 

Date:____________

Supersedes: 

N/A 

Project Manager: 

__________________________

John Stiver, CHP 

 Date:____________

Peer Reviewer(s): 

 John Mauro

 Steve Marschke 

 John Stiver 

 

 

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 07/30/2015 Initial issue

 

 

 

 

 

 
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TABLE OF CONTENTS 

Abbreviations and Acronyms ..........................................................................................................4

Introduction ......................................................................................................................................6

Background ......................................................................................................................................7

1

st Residual Period ...........................................................................................................................8

2

nd Residual Period ........................................................................................................................15

3

rd Residual Period .........................................................................................................................16

Summary ........................................................................................................................................18

References ......................................................................................................................................19

LIST OF TABLES 

Table 1. General Area Gross Alpha Samples Taken at WEC before Any Processing Work 

was Done during 2nd Operating Period ...........................................................................8

Table 2. Decay of Air Concentration with Time during 1st Residual Period ................................10

Table 3. Comparison of Residual Period Inhalation Intakes ........................................................11

Table 4. Mode 2 Ingestion Intakes during 1st Residual Period (based on 8-hr workday). ............12

Table 5. Ingestion Intakes for 1st Residual Period. .......................................................................14
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ABBREVIATIONS AND ACRONYMS 

ABRWH Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

AWE Atomic Weapons Employer 

BZ breathing zone 

d day 

DOE (U.S.) Department of Energy 

DWA daily weighted average 

dpm/d disintegrations per minute per day 

dpm/m2 disintegrations per minute per square meter 

dpm/m3 disintegrations per minute per cubic meter 

ER Evaluation Report 

GA general area 

HASL Health and Safety Laboratory 

hr hour 

λ/sec lambda per second 

m meter 

m

2 square meter 

μg/m2/sec microgram per square meter per second 

μg/m3 microgram per cubic meter 

MAC maximum allowable air concentration 

MED Manhattan Engineer District 

m/s meters per second 

NIOSH National Institute for Occupational Safety and Health 

NRC (U.S.) Nuclear Regulatory Commission 

OCAS Office of Compensation Analysis and Support 

ORAUT Oak Ridge Associated Universities Team 

ORISE Oak Ridge Institute for Science and Education 

RESRAD residual radiation 

rpm revolutions per minute 

SC&A S. Cohen and Associates (SC&A, Inc.) 

SEC Special Exposure Cohort 
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sec/hr seconds per hour 

SRDB site research database 

TBD technical basis document 

TIB technical information bulletin

WEC Westinghouse Electric Corporation 

y year 
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INTRODUCTION 

At the June 9, 2015, teleconference meeting of the Advisory Board on Radiation and Worker 

Health (ABRWH), the Board tasked SC&A to conduct a review of the Special Exposure Cohort 

(SEC) Petition Evaluation Report (ER) for Petition SEC-00217, Westinghouse Electric 

Corporation, New Jersey, issued by the National Institute for Occupational Safety and Health 

(NIOSH) on April 14, 2015 (NIOSH 2015). The review was to focus on the residual periods 

only. This report presents SC&A’s review as requested by the Board. 

NIOSH had previously reviewed Petition SEC-00157 for the Westinghouse New Jersey Plant 

(NIOSH 2010) and, at that time, proposed in the Petition Evaluation Report dated January 10, 

2010, the following addition to the SEC: 

All Atomic Weapons Employer employees who worked at Westinghouse Electric Corp., 

Bloomfield, New Jersey, from August 13, 1942, through December 31, 1949, for a number of 

work days aggregating at least 250 work days, occurring either solely under this employment, 

or in combination with work days within the parameters established for one or more other 

classes of employees included in the Special Exposure Cohort. 

The period from August 13, 1942, through December 31, 1949, is referred to here as the 

1

st operating period. 

Although it was noted in the ER for SEC-00157 (NIOSH 2010) that the site “had a residual 

radiation period of 1950 through July 2006,” no approach to reconstructing doses during the 

residual period was presented. 

Subsequently, a petitioner requested that Westinghouse workers be added to the SEC for the 

period after that proposed under SEC-00157 as follows (NIOSH 2010): 

All Atomic Weapons Employer employees who worked at any plant production 

area of Westinghouse Electric Corporation in Bloomfield, New Jersey, from 

January 1, 1950 through March 1, 2011. 

This petition was qualified by NIOSH on January 8, 2015, and, as noted above, the ER was 

issued on April 14, 2015 (NIOSH 2015). NIOSH determined that two additional operating 

periods had occurred during the timeframe under review: 

 February 1, 1958, through May 31, 1958 (2nd operating period) 

 June 1, 1959, through June 30, 1959 (3rd operating period) 

NIOSH also determined that the end date for the residual period should be April 30, 2000, the 

date that final remediation was completed. Based on these findings, the three residual periods 

were defined by NIOSH in the SEC-00217 ER: 

 January 1, 1950, through January 31, 1958 (1st residual period) 

 June 1, 1958, through May 31, 1959 (2nd residual period) 

 July 1, 1959, through April 30, 2000 (3rd residual period) 
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BACKGROUND 

Operations at the Westinghouse New Jersey Plant are described in adequate detail in the SEC00217 ER (NIOSH 2015) and will not be repeated here. However, for the reader’s convenience,

we have extracted the following summary from NIOSH 2015 (Section 5.1.1): 

During World War II, WEC was contracted to produce uranium in support of the 

MED. Operations during this period, from August 1, 1942 through December 31, 

1949, are also described in SEC Petition Evaluation Report for Petition SEC00159 (NIOSH, 2010). 

WEC developed a photochemical technique to produce uranium metal using 

uranium oxide or nitrate and potassium fluoride. The process was used to 

produce limited quantities of uranium. (Under the best weather conditions with 

good sunlight, the process could produce 1 ton/month.) The green salt produced 

by the reaction was electrolyzed to yield uranium metal that was subsequently 

cast into discs, pellets, and ingots (DOE, undated). The contract began on August 

1, 1942 (DOE, undated) and was completed on October 15, 1943 (Unspecified, 

1942–1943), and would have been capable of producing a total of 14.5 tons of 

uranium metal. At the end of this contract in 1945, the process equipment was 

removed (DOE, undated) and the uranium production facility was deactivated. 

After deactivation, the basement area was used primarily as a research testing 

laboratory (Westinghouse, 1980, PDF p. 30). 

WEC also worked with thorium under contract W-7409-ENG-31 for the MED. 

They produced a total of 200 pounds of thorium metal in the form of bars, tubes, 

sheets, and wire in early 1945 (Uranium, undated, PDF p. 4). 

WEC also performed natural uranium machining operations for Fernald during 

short-term projects under contract from February 1958 through May 1958 and 

throughout June 1959. During these projects, WEC performed test rollings of 

uranium tubes on the Assel Mill to evaluate whether this process could be used to 

elongate hollow fuel rods for eventual use in a nuclear reactor as part of the 

nuclear weapons production complex (Simmons, 1959, PDF p. 74). The actual 

machining was scheduled to take one or two days (Kirkman, 1958, PDF p. 6), and 

the first test was attended by a Health and Safety Laboratory (HASL) 

representative, May 12 through May 16, 1958 (Ross, 1958). The work was 

performed on a No.1 Witter mill (also known as an Assel mill) (Simmons, 1958 

[sic], PDF p. 100). The first test was unsuccessful because of excessive slippage 

between the work piece and the roll surfaces. A second rotary-elongation test 

was conducted on the same mill in June 1959. The actual machining during this 

second test occurred from June 25 through June 29, 1959, as indicated by the air 

monitoring dates (Monitoring, 1959). The mill-roll speed was reduced to 43 rpm 

(128 rpm was used in the previous test) (Steck, 1963). 
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NIOSH is not aware of any additional uranium machining operations at WEC 

after June 30, 1959 (Ansari, 1993, PDF p. 12). 

1

ST RESIDUAL PERIOD 

For the 1st residual period, NIOSH proposed in the SEC-00217 ER to use air sampling data 

obtained at the beginning of the 2nd operating period, but before any processing of uranium had 

occurred. At the beginning of the 2nd operating period, air sampling was conducted by the New 

York Operations Office of the Atomic Energy Commission’s (AEC’s) Health and Safety 

Laboratory (HASL). A total of 7 breathing zone (BZ) and 39 general area (GA) air samples 

were analyzed for gross alpha during the 2nd operating period. Samples taken before any 

uranium processing on the Assel Mill was done are summarized in Table 1 (NIOSH 2015, 

Figure 7.1). 

Table 1. General Area Gross Alpha Samples Taken at WEC before Any Processing Work 

was Done during 2nd Operating Period 

Sample Description Number of 

Samples

3 Concentration (dpm/m ) % MACa

High Low Average

Assel Mill operator’s platform 5 5 1 2 0.02

Assel Mill 8 12 2 5 0.07

Argon furnace 2 23 1 12 0.17

a – maximum allowable air concentration (MAC) = 70 dpm/m3

Based on the HASL sampling, NIOSH selected the highest average concentration of 12 dpm/m3

as the initial air concentration prior to processing uranium on the Assel Mill. NIOSH assumed 

that this air concentration was the result of surface contamination during the 1st operating period 

that was resuspended during the 1st residual period. Using the default depletion constant from 

ORAUT-OTIB-0070 (ORAUT 2012), NIOSH proposed to extrapolate this air concentration 

backwards in time to obtain the gross air concentration at the beginning of the 1st residual period. 

As described in ORAUT-OTIB-0070, Section 4.1.1 (ORAUT 2012), NIOSH assumed that 

airborne activity decayed at an exponential rate of 0.00067/day. This average decay rate was

obtained from four work sites examined by NIOSH. Assuming that the air concentration was 

12 dpm/m3in 1958, it can be calculated, using the adjustment factors in Table 4-2 for OTIB0070, that the air concentration at the beginning of the 1st residual period would have been 

85 dpm/m3. However, this approach is not consistent with what is recommended in OTIB-0070. 

Per Table 5-1 of OTIB-0070, when the post-operational air concentration is known, the 

recommended approach is to use an: 

Exponential fit of postoperational data and estimate of operational airborne 

radioactivity based on ORAUT (2006)1or Battelle (2011). 

NIOSH does not recommend simply back-extrapolating the post-operational data using the 

generic decay constant of 0.00067/day. 

 

1

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In its supplemental review of TBD-6000 (Battelle 2011), SC&A noted that, at the Hanford Melt 

Plant (Adley et al. 1952): 

 The removal rate at equilibrium of uranium oxide particles deposited on surfaces was 

estimated to be 0.035/day. This rate is considerably higher than the removal rate of 

0.00067/day developed in ORAUT-OTIB-0070 (ORAUT 2012). The calculations 

presented here support the position that the OTIB-0070 approach regarding time to reach 

equilibrium is claimant favorable.

That conclusion was premised on the fact, while the net removal rate could be higher than the 

value of 0.00067/day, higher rates would result in earlier depletion of contamination and, 

consequently, lower doses. However, the conclusion regarding claimant-favorability is 

predicated on using the decay rate to project future air concentrations. In the case of SEC-00217, 

we believe that, for the first time in dose reconstruction, the decay rate is being used to project

backwards in time to predict a previous concentration. In the reverse mode, if the decay rate is 

higher than the generic value of 0.00067/day, then the derived initial concentration would be 

higher. While the forward mode appears to be claimant-favorable, the reverse mode does not. 

Based on the Adley et al. (1952) data, it can be assumed that there may be some sites where the 

decay constant for reduction of particles resuspended in the air is higher than for the four sites 

examined in OTIB-0070. While the OTIB-0070 approach is acceptable when using air 

concentrations at the cessation of operations to estimate future air concentrations in a claimantfavorable manner (because the OTIB-0070 decay rates are low), the reverse is not true. Using 

the OTIB-0070 decay constant of 0.00067/day and the air concentration at the end of the residual 

period to calculate air concentrations at the beginning of the residual period will not be claimantfavorable if the decay constant is higher than that developed in OTIB-0070.

Finding 1. The procedure for calculating air concentrations during the 1st residual period is not 

consistent with the guidance provided in ORAUT-OTIB-0070.

No specific guidance is included in Table 5-1 of OTIB-0070 as to how to use TBD-6000 

(Battelle 2011). However, two possibilities suggest themselves. One is to use the air 

concentration data for the appropriate operation from Section 7 of TBD-6000 (Battelle 2011) and 

assume this is the concentration at the end of the operational period and the beginning of the 

residual period. For example, from Table 7.3 of Battelle (2011), the geometric mean air 

concentration for rolling uranium is 3,533 dpm/m3(DWA). Using the exponential decay 

equation (OTIB-0070, Equation 4-1): 

A(residual period) = A(operations)* e-λt

and assuming the air concentration in year 1 is 3,533 dpm/m3and in year 8 is 12 dpm/m3, the 

decay constant (λ) is 0.218/y. However, this approach sets the initial air concentration at an 

unrealistically high level. 

The second approach is to estimate the equilibrium surface concentration as described in 

Section 3.42 of TBD-6000: 
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Using a 30 day deposition time and a 0.00075 m/s settling rate, a deposition 

factor of 1944 meters can be calculated. The floor contamination level is then 

estimated as Floor Concentration (dpm/m2) = Air Concentration (dpm/m3) × 

1944 meters. 

Using this methodology, the floor concentration at the end of operations would be 

6.87E+06 dpm/m2(3,533 × 1944). This material would rapidly fall out of the atmosphere at the 

end of operations. The air concentration at the beginning of the residual period will be the result 

of resuspending some of this material. For example, based on a resuspension factor of 1E-05/m, 

the air concentration would be 69 dpm/m3. While the second approach results in a considerably 

lower air concentration, we believe that the second approach is based on a more realistic model 

for the physical processes of deposition and resuspension that would be occurring. At the 

cessation of operations, the air concentration will drop dramatically, as no new contamination is 

being generated. The reduction in air concentration over time based on the decay factor cited 

above is given in Table 2.

Table 2. Decay of Air Concentration with Time during 1st Residual Period 

Year Faction of Initial

Concentration Remaining

1950 1.000

1951 0.804

1952 0.647

1953 0.520

1954 0.418

1955 0.336

1956 0.270

1957 0.217

1958 0.175

In the “sample DR” developed by NIOSH for Westinghouse, the estimated air concentration at 

the beginning of the residual period was 85 dpm/m3(Spreadsheet 2015). While this value is not 

significantly different from the air concentration of 69 dpm/m3

developed here, we believe that 

the approach taken here is consistent with the recommendations of OTIB-0070. These air 

concentrations are compared with those developed by NIOSH in the sample DR prepared for 

Westinghouse in Table 2. It should be noted that the inhalation intakes presented here are per 

calendar-day. To convert to dpm/work-day, the values in Table 3 should be multiplied by 

365/250.

Although the results in intakes differ only slightly, the approach based on the guidance in 

Table 5-1 of OTIB-0070 should be used to insure that the relevant guidance documents are 

correctly employed. 
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Table 3. Comparison of Residual Period Inhalation Intakes 

Year Air Concentration (dpm/m3

) Daily Inhalation Intake (dpm/day)

SC&A Approach NIOSH Approach SC&A Approach NIOSH Approach

1950 6.87E+01 8.49E+01 4.52E+02 5.58E+02

1951 5.52E+01 6.65E+01 3.63E+02 4.37E+02

1952 4.44E+01 5.21E+01 2.92E+02 3.42E+02

1953 3.57E+01 4.08E+01 2.35E+02 2.68E+02

1954 2.87E+01 3.19E+01 1.89E+02 2.10E+02

1955 2.31E+01 2.50E+01 1.52E+02 1.64E+02

1956 1.86E+01 1.96E+01 1.22E+02 1.29E+02

1957 1.49E+01 1.53E+01 9.81E+01 1.01E+02

1958 1.20E+01 1.20E+01 7.89E+01 7.89E+01

Ingestion Doses 

NIOSH states in OCAS-TIB-009 (NIOSH 2004), Section 5, that: 

The amount of activity ingested on a daily basis can be approximated by 

assuming it to be 0.2 times the activity per cubic meter of air. (NIOSH 2004) 

The ingested activity is assumed to be equally contributed from two sources: 

 Mode 2 – material settling from the air onto food and drink, which is then consumed. 

This term must be adjusted based on the work schedules, as discussed below.

 Mode 3 – material settling on the surfaces, then transferred to the hands and finally 

transferred to the mouth.

During operations, airborne dust is generated by some processes such as rolling or machining. 

The dust falls onto the surface at a rate determined by the air concentration and the terminal 

settling velocity of the dust particles (μg/m3× m/s = μg/m2/sec). This surface contamination is 

removed by various processes until the rate of deposition equals the rate of removal and an 

equilibrium concentration is reached. The removal rate equals the surface concentration times a 

removal constant (μg/m2× λ/sec) i.e., air concentration × settling velocity = surface 

concentration × decay rate. If operations are of sufficient duration (i.e., 30 days per TBD-6000), 

equilibrium will be reached.

During the residual period, there is no source to replenish contamination removed over time. 

Both the Mode 2 and Mode 3 ingestion sources are dependent on the level of surface 

contamination, with the airborne concentration driven by resuspension of residual surface 

contamination. 

OTIB-0070 (Section 3.6) provides the following guidance for calculating ingestion intakes 

during the residual period: 

If inhalation intakes are calculated from air concentrations, ingestion intakes are 

to be considered. The ingestion rate, in terms of disintegrations per minute (dpm) 
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for an 8-hour workday, can be estimated by multiplying the air concentration in 

dpm per cubic meter by a factor of 0.2 (NIOSH 2004). 

At the January 22, 2015, meeting of the Uranium Refining AWE Work Group, the use of OCASTIB-009 (NIOSH 2004) for estimating ingestion during the residual period was discussed 

extensively (ABRWH 2015). NIOSH pointed out that the TIB-009 ingestion model used 

airborne contamination in calculating hand-to-mouth transfer of contamination when, in fact, the 

proper basis should be surface concentration (ABRWH 2015, p. 58), and that in general:

... since TIB-9 kind falls apart for the residual period, and we actually had 

contamination measurements as a starting point, it really couldn't be used and 

reverted back to what Jim used from the NUREG..... (ABRWH 2015, p. 61) 

Both of the ingestion modes described above depend on the surface concentration, which 

decreases with time during the residual period. The Mode 2 ingestion during the residual period 

is the result of resuspended surface contamination that falls on food and drink, while the Mode 3 

ingestion involves transfer of surface contamination to the hands and then to the mouth. The 

ingestion component from Mode 2 is the airborne concentration, while the ingestion component 

from Mode 3 is the surface concentration. 

In OCAS-TIB-009 (NIOSH 2004), Mode 2 ingestion (i.e., airborne dust settling on a 3-in 

diameter cup of coffee) is calculated as follows: 

Air concentration (A dpm/m3) × terminal settling velocity (0.00075 m/s) × cup area (0.00456 m2) 

× settling time (8, 8.8, or 9.6 hr/day) × 3,600 sec/hr. 

For an 8-hr day, the Mode 2 ingestion rate is 0.0984 A dpm/day. These air concentrations were 

shown previously in Table 2 based on the SC&A and NIOSH derivational approaches. The 

Mode 2 ingestion is summarized in Table 4. Note that the intakes are on a work-day basis. 

Table 4. Mode 2 Ingestion Intakes during 1st Residual Period (based on 8-hr workday). 

Year Daily Ingestion Intake (dpm/work-day)

SC&A Approach NIOSH Approach

1950 6.76E+00 8.35E+00

1951 5.43E+00 6.54E+00

1952 4.37E+00 5.12E+00

1953 3.51E+00 4.01E+00

1954 2.82E+00 3.14E+00

1955 2.27E+00 2.46E+00

1956 1.83E+00 1.93E+00

1957 1.47E+00 1.51E+00

1958 1.18E+00 1.18E+00
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In OCAS-TIB-009 (NIOSH 2004), Mode 3 ingestion (hand-to-mouth transfer) is calculated as 

follows:

Air concentration (A dpm/m3) × terminal settling velocity (0.00075 m/s) × hand-to-mouth 

transfer factor (0.1) × area of hand (0.0155 m2) × 24 hr/d × 3,600 sec/hr = 0.1 A dpm/d

It is not possible to deduce from this equation what is the implied surface concentration, because 

the settling time is not explicitly defined. Since, as discussed above, TIB-009 (NIOSH 2004) has 

been judged not to be appropriate for the calculating ingestion via hand-to-mouth transfer during 

the residual period, an alternate method is needed. One possibility would be to use the guidance 

in TBD-6000 (Battelle 2011) coupled with the approach documented in RESRAD-BUILD (Yu et 

al. 2000). The authors of that document recommend in Table 2.7 a default value of 0.0001 m2/hr

for the receptor indirect ingestion rate.2 Using this rate and the surface concentration at the 

beginning of the 1

st residual period of 6.78E+06 dpm/m2

(30 days × 0.00075 m/s × 24 hr/day ×

3,600 sec/hr × 3,533 dpm/m3) per TBD-6000, the daily ingestion from this source during the first 

year of the residual period is 5,496 dpm/day (6.87E+06 dpm/m2× 0.0001 m2/hr × 8 hr/day). 

However, as noted in NUREG/CR-5512, Volume 3 (NRC 1999): 

...the actual amount of contamination ingested will also depend on other factors, 

including the fraction F, of the total source term that is "loose," and therefore 

available for ingestion.

Alternatively, Yu et al. 2000, Section 8.3, gives the removable fraction most likely value as 0.2. 

On the other hand, NUREG/CR-5512, Volume 3, Section 5.5.1 states:

10% of the measured source concentration was assumed to be removable.

Thus, based on the RESRAD approach, the initial ingestion exposure during the 1

st residual 

period would range from 1,099 to 550 dpm/d.

This value would be reduced in subsequent years based on Table 2. This approach results in 

substantially higher Mode 3 intakes than would result from using OCAS-TIB-009 (NIOSH 

2004), as shown in Table 5, using the mostly likely value of 1,099 dpm/d for receptor indirect 

ingestion rate. The values in the last column are NIOSH values from Spreadsheet 2015.

 

2 The receptor indirect ingestion rate is defined as: The rate at which an individual ingests deposited dust 

after it has transferred to hands, foods, or other items at each receptor location. 
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Table 5. Ingestion Intakes for 1st Residual Period.

Year Mode 2 ing.

dpm/day

Mode 3 ing.

dpm/d

Total ing.

dpm/d

Total ing.

dpm/cal-day

NIOSH DR

dpm/cal-day

1950 1.000 6.76E+00 1.10E+03 1.11E+03 7.57E+02 1.16E+01

1951 0.804 5.43E+00 8.84E+02 8.89E+02 6.09E+02 9.11E+00

1952 0.647 4.37E+00 7.10E+02 7.15E+02 4.90E+02 7.13E+00

1953 0.520 3.51E+00 5.71E+02 5.75E+02 3.94E+02 5.58E+00

1954 0.418 2.82E+00 4.59E+02 4.62E+02 3.17E+02 4.37E+00

1955 0.336 2.27E+00 3.69E+02 3.72E+02 2.55E+02 3.42E+00

1956 0.270 1.83E+00 2.97E+02 2.99E+02 2.05E+02 2.68E+00

1957 0.217 1.47E+00 2.39E+02 2.40E+02 1.65E+02 2.10E+00

1958 0.175 1.18E+00 1.92E+02 1.93E+02 1.32E+02 1.64E+00

Finding 2. The guidance provided in OTIB-0070 [ORAUT 2012] (Section 3.6) for calculating 

doses during the residual period refers to OCAS-TIB-009 (NIOSH 2004). This guidance should 

be revised since the TIB-009 approach cannot be used to calculate ingestion intakes from 

transfer of surface contamination to the hands and then to the mouth. Use of the procedure in 

TIB-009 understates this source of ingestion. The calculations in the SEC-00217 ER for the 1st

residual period should be modified accordingly.

In SEC-00217, NIOSH states that:

NIOSH concludes that there are methods available in Battelle-TBD-6000 [Battelle 

2011], OCAS-TIB-009 [NIOSH 2004], and ORAUT-OTIB-0070 [ORAUT 2012], as 

well as available air data and operational descriptions, so that internal radiation 

doses can be completely reconstructed with sufficient accuracy for all AWE 

employees during the following periods under evaluation:

• All employees during the residual radiation period from January 1, 1950 through 

January 31, 1958 

• All employees during the residual radiation period from June 1, 1958 through 

May 31, 1959 

• All employees during the residual radiation period from July 1, 1959 through 

April 30, 2000 

Thus, NIOSH concluded that ingestion doses for the all three residual periods can be 

reconstructed using OCAS-TIB-009 (NIOSH 2004). Using the TBD-6000 (Battelle 2011) 

methodology, the following assumptions should be made regarding hours worked per week:

 1950 – 48 hours (9.6 hr/day)

 1951–1955 – 44 hours (8.8 hr/day)

 After 1955 – 40 hours (8 hr/day)
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We note in the sample DR for WEC (Spreadsheet 2015) that these adjustments are not made. 

Rather a constant 8 hr/d is assumed. As discussed below, this correction should be applied to the 

Mode 2 ingestion doses. We recognize that the adjustment is minor, but the logic behind the 

calculational methodology should be preserved.

Observation 1. Mode 2 ingestion exposures based on OCAS-TIB-009 should be adjusted for the 

duration of the work-day (i.e., 8, 8.8 or 9.6 hr) based on the dates which the exposures occurred.

2

ND RESIDUAL PERIOD

For the 2nd residual period (June 1, 1958, through May 31, 1959), NIOSH assumed that the air 

concentration remained constant at 12 dpm/m3. The basis for this assumption is as follows 

(NIOSH 2015):

During the 2nd operational period, an on-site representative from HASL collected 

4 general-area, gross-alpha air samples “after all clean-up and decontamination 

work was done” (see Figure 7.1 above) (Ross, 1958). NIOSH will assume that 

the average of these 4 samples (12 dpm/m3) is representative of the air 

concentration at the start of this residual radiation period. Since the length of 

this residual radiation period is approximately one year, no source term depletion 

was applied. NIOSH will apply the air concentration of 12 dpm/m3in a constant 

manner to model activity available for inhalation and ingestion by personnel 

during this period.

It should be noted that it is coincidental that the air concentration at the beginning and end of 

the 2nd operational period was the same (12 dpm/m3). The basis for the airborne 

concentration value at the beginning of the 2nd operational period was described in Table 1,

while the basis for the concentration at the end of that period is provided in the quotation 

above.

Although the 2

nd operating period was defined as February 1, 1958, through May 31, 1958

(the contract period), actual rolling operations on the Assel mill only occurred from May 

12–16, 1958, when six uranium fuel rods were processed. During operations, both BZ 

and GA air samples were taken by HASL. For four GA samples taken on the Assel mill 

platform during rolling, the average air concentration was 2,412 dpm/m3, and for two GA 

samples taken at the Assel mill during rolling, the average air concentration was 

1,544 dpm/m3. A bounding estimate of the surface concentration can be made by 

assuming that rolling occurred over four 8-hour work-days for 25% of each work-day. 

Assuming an average air concentration of about 2,000 dpm/m3and 8 hours of deposition, the 

surface concentration at the end of operations would be 43,200 dpm/m2(2,000 dpm/m3×

0.00075 m/s × 3,600 sec/hr × 8 hr).

3

 If the resuspension factor is 1E-05/m, then the air 

concentration would be 0.4 dpm/m3. This calculation is clearly bounding, since cleanup and 

decontamination were done after 2nd period operations were complete (Ross 1958). Thus, the 

 

3 We presume that, since the operations were limited in scope, it is reasonable to assume that deposition 

should be based on an 8-hr day rather than a 24-hr day.
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assumption of 12 dpm/m3for the air concentration in the 2nd residual period is reasonable and 

claimant favorable for inhalation intakes.

With regard to ingestion intakes, the same conceptual issue exists as was discussed for the 1

st

residual period; i.e., the need to use surface concentration to estimate hand-to-mouth 

ingestion. Assuming, for discussion, that the surface concentration is 43,200 dpm/m2, the 

daily ingestion based on an indirect ingestion rate of 0.0001 m2/h is 35 dpm/work-day 

(43,200 dpm/m2× 0.0001 m2/h × 8 hr/work-day). The Mode 2 contribution to ingestion 

based on an air concentration of 0.4 dpm/m3is 0.4 dpm/work day (0.4 dpm/m3× 0.00075 m/s 

× 0.0456 m2× 3,600 sec/hr × 8 hr/work-day). The total ingestion intake would be 24 dpm/

calendar-day. For comparison, NIOSH developed an estimate of 1.64 dpm/d based on 

OCAS-TIB-009 (NIOSH 2004) methodology.

Finding 2 is applicable to the 2nd residual period as well. 

3

RD RESIDUAL PERIOD 

For the 3rd residual period (July 1, 1959, through April 30, 2000), NIOSH used air-sampling data 

from the 3rd operating period. As described by NIOSH (2015, Section 5.2.1.1):

The third AWE contract started on June 1, 1958 and ended on June 30, 1959; 

however, NIOSH found indications that potential uranium machining exposures 

occurred only during operations from June 25, 1959 through June 29, 1959. 

During the 3rd operational period, HASL collected 27 gross alpha air samples (both BZ and GA). 

The highest observed value was 5,551 dpm/m3for a BZ sample. Based on that sample, NIOSH 

proposed to calculate the surface concentration for the 5 days over which rolling of uranium was 

actually conducted. Airborne concentrations resulting from resuspension would be based on a 

resuspension factor of 1E-05/m. Based on the methodology proposed by NIOSH, SC&A has 

estimated the initial surface concentration to be 6.00E+05 dpm/m2(5,551 dpm/m3× 

0.00075 m/s × 3,600 sec/hr × 8 hr/day × 5 days) and that the initial airborne concentration would 

be 6 dpm/m3. NIOSH further proposes that this concentration be decayed over time, based on 

the source term depletion factors developed in Table 4-2 of OTIB-0070 (ORAUT 2012).

This approach to developing surface and airborne concentrations is reasonable and should 

provide an appropriate basis for calculating inhalation intakes during the 3rd residual period. The 

concerns discussed above regarding use of the OCAS-TIB-009 (NIOSH 2004) methodology for 

calculating ingestion intakes also apply to the 3rd residual period.

As a sidebar comment, we note in Spreadsheet 2015 (Sheet: Res 6-30-1959 to 4-30-2000) that 

the initial surface concentration is 10,791,144 dpm/m2. This is the surface concentration that 

would be obtained from 30 days of round-the-clock deposition. Such an estimate would be 

appropriate for an extended production operation, but not for the limited 3rd operational period at 

Westinghouse. This approach is inconsistent with that documented on page 37 of NIOSH 2015,

which states:
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The estimate of surface contamination will be made by assuming continuous 

settling of this airborne radioactive material at a rate of 0.00075 m/s for 5 days. 

Observation 2. The deposition time used in the Model DR (Spreadsheet 2015) is not consistent 

with that proposed on p. 37 of NIOSH 2015.

As described in the SEC-00217 ER, NIOSH proposes to increase the resuspension factor to 

1E-04/m for the period from November 1, 1976, through April 30, 2000, to account for the 

effects of aggressive decontamination activities on resuspension. This adjustment is appropriate,

given the known history of the site.
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SUMMARY

Based on its review of how NIOSH proposed to address exposures during the residual periods at 

WEC, SC&A has two findings and two observations:

Observation 1. Mode 2 ingestion exposures based on OCAS-TIB-009 should be adjusted for the 

duration of the work-day (i.e., 8, 8.8 or 9.6 hr) based on the dates which the exposures occurred.

Observation 2. The deposition time used in the Model DR (Spreadsheet 2015) is not consistent 

with that proposed on p. 37 of NIOSH 2015.

Finding 1. The procedure for calculating air concentrations during the 1st residual period is not 

consistent with the guidance provided in ORAUT-OTIB-0070.

Finding 2. The guidance provided in OTIB-0070 (Section 3.6) for calculating doses during the 

residual period refers to OCAS-TIB-009 (NIOSH 2004). This guidance should be revised, since 

the OCAS-TIB-009 approach cannot be used to calculate ingestion intakes from transfer of 

surface contamination to the hands and then to the mouth. Use of the procedure in TIB-009 

understates this source of ingestion. The calculations in the SEC-00217 ER for the 1st residual 

period should be modified accordingly.

Finding 2 is applicable to all three residual periods. Implementation of this finding will require 

revisions not only to the SEC-00217 ER, but also to OCAS-TIB-009 (NIOSH 2004) and 

ORAUT-OTIB-0070 (ORAUT 2012).

It is recognized that these corrections will result in small changes to the residual period doses; 

however, the corrections should be made to ensure that a consistent and scientifically sound 

calculational methodology is preserved.
Effective Date:

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